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ARTICLE · 16 AUGUST 2016

FDIC Proposes Examination Guidance For Third-Party Lending Arrangements

Troutman Pepper Locke LLP
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The Federal Deposit Insurance Corporation is seeking comment on proposed examination guidance for Third-Party Lending.

United StatesConsumer Protection
Alan Wingfield
Alan Wingfield
Daniel Howell
Daniel Howell
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The Federal Deposit Insurance Corporation ("FDIC") is seeking comment on proposed examination guidance for Third-Party Lending. [1] The proposed guidance, issued July 29, provides banks with safety, soundness and consumer compliance measures to be followed when lending through a business relationship with a third party. The proposed guidance will apply to all banks that engage in third-party lending, and will also affect all institutions that seek to originate loans with banks. The proposed guidance, while appearing technical, follows a pattern of federal regulators showing increased interest in holding financial institutions accountable for the acts of those who they do business with, resulting in increased risk and increased compliance burdens on all involved.

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